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Wednesday, May 18, 2011

American Rivers Mistakenly Designates Susquehanna Most Endangered River

American Rivers does important work but its designation of the Susquehanna as the most endangered river in the nation due to gas drilling is mistaken.

The Susquehanna does face pollution challenges like many rivers, but those are mainly pollution run-off from agricultural lands, sewer plant discharges, run-off from urban areas, and fertilized lawns.

All of these real threats to the Susquehanna are stable or declining. For example, in the case of sewer discharges, over a 150 municipal sewer plants discharging to the Susquehanna or tributaries have installed improved pollution controls since 2008 or will be doing so shortly. The amount of poorly treated sewage going into the Susquehanna is declining.

Progress is being made on reducing pollution running off land. Thousands of miles of new riparian buffers have been installed. Huge amounts of cover crops are now planted in the Susquehanna River Basin area.

The riparian buffers and the cover crops are just two of many practices required by the Total Maximum Daily Load Limit or pollution limit that has been in place since December 2010 for the entire Chesapeake Watershed that includes centrally the Susquehanna River. EPA and the federal courts are enforcing the TMDL. So with the TMDL in place, the Susquehanna has never been better protected by law than today.

So if the major, existing threats to the Susquehanna are stable or declining, what about gas drilling? American Rivers points to two factors that concern it about gas drilling: water withdrawals and discharges of drilling waste water to the river.

Water withdrawals for drilling from the Susquehanna and all of Pennsylvania's streams have been tightly regulated by the Pennsylvania Department of Environmental Protection and the Susquehanna River Basin Commission since the fall of 2008. Since then, when drillers apply for a drilling permit, they must file a water plan specifying from where water for fracking is coming and how much will be used. The withdrawal is only approved if it would not harm a stream in a drought condition. A drought is assumed to be an all the time condition.

Total withdrawals of water from streams for Marcellus drilling is about 2 million gallons per day. Sounds like a lot. But 9.48 BILLION gallons are withdrawn every day for all purposes in Pennsylvania. Marcellus drilling accounts for less than 0.2% of all water withdrawn each day.

Water withdrawals for drilling are not threatening at all the Susquehanna River.

But what about disposal of frack fluids without treatment for Total Dissolved Solids (TDS) to the Susquehanna river? Is not that a threat?

The one plant that was discharging frack fluids not treated for TDS to the Susquehanna stopped doing so on May 1st. And the August 2010 new, strong TDS rule that drinking water companies and environmental groups all fought successfully to get passed will stop any new treatment plants from disposing frack fluids without completely treating for TDS to the Safe Drinking Water Act standard at the pipe to the river. All new plants must comply. Eureka is one such company that treats frack fluids completely to the Safe Drinking Water Standard and operates daily in Williamsport.

Moreover the August 2010 rule puts in place a watershed, cumulative standard requiring DEP to prevent the waters of the Susquehanna and all other watersheds from reaching the 500 mg/liter Safe Drinking Water Standard.

American Rivers should also know that at least 70% of frack fluids are treated by recycling plants and then reused in gas wells. The recylcing water technology did not exist in 2008 but is now widely deployed.
Frack fluid recycling reduces water withdrawals and manages safely frack fluids.

In addition frack water that is not being recycled or treated is being injected into deep underground caverns that are thousands of feet away from ground water and that are regulated by the EPA.

Frack water is not being discharged into the Susquehanna River and won't be.

In fact, tomorrow May 19th could be the day when Pennsylvania nearly reaches or does achieve an important milestone. That milestone would be reducing frack fluid discharges into our streams below the levels that existed prior to the first Marcellus well being drilled in 2005.

DEP has asked the few, old plants anywhere in the Commonwealth that have been discharging drilling fluids without TDS treatment to stop doing so. If they do so or DEP makes them do so, less frack fluids will be going into our streams than in decades.

All this is good news and means the Number 2 river on the American Rivers list is actually America's most threatened.

2 comments:

You say with such confidence: "Water withdrawals for drilling are not threatening at all the Susquehanna River."

So American Rivers has no need for their concern:"The seriousness of the threat to the entire Susquehanna watershed cannot be overstated. Industry estimates indicate the potential for 400,000 wells across the Marcellus Shale – a number that would require, conservatively, 1.5 times the annual flow of the Susquehanna River to sustain. As part of the hydraulic fracturing (or ‘fracking’) process to extract natural gas, massive amounts of water are withdrawn from rivers and streams. Many of the streams being used for Marcellus Shale water withdrawals provide critical habitat for trout – a concern, especially during summer months when stream flows are already low."

I assume their estimates of a potential 400,000 wells might well be excessive. But just 1000 wells x 2 million gallons...is a lot of water.

And what about their concern: "Already, spills from trucks hauling wastewater, leaks from lined fluid holding pits, and cracked well casings have contaminated private water wells. The potential for future environmental and public health catastrophes along the Susquehanna will only increase, considering the number of new wells projected and the amount of toxic wastewater produced."

I am sorry but I would rather go with their recommendation – "Pennsylvania, New York, and the Susquehanna River Basin Commission need to announce a complete moratorium on water withdrawals and hydraulic fracturing until there are comprehensive regulations in place for natural gas development or they will put public health and drinking water at risk." – and wait until the studies are in. Is it just casement leaks on the upper levels that cause migrations of shallow gas into aquifers and home water wells? Because the fracturing explosions are 1 mile + down, are they really safe and not disturbing the environment in a harmful way? You too easily dismiss the inherent dangers, and thereby promote a reckless industrialization of Pennsylvania.

I appreciate your comment. It engages seriously with the numbers about water withdrawals. Please see the April 5th posting on this blog entitled: "See the Top 9 water users and where drillers rank." The data comes from the Susquehanna River Basin Commission and has been endorsed by the Pennsylvania Fish and Boat Commission. In one sense 2 million gallons is a lot of water. But 2 million gallons withdrawn by drillers in terms of the total water withdrawn every day from rivers is the proverbial drop in the bucket. Again it is LESS than 0.2% of all water withdrawn. 2 million gallons is even a smaller percentage of the total daily flow of water in our rivers. The Susquehanna itself has an enormous total flow, in the trillions of gallons each year. Also again water withdrawals are tightly regulated and have been since 2008 when a water plan must be filed with the drilling permit. And again the water withdrawal decision is based on a protective standard. The standard assumes that streams are ALWAYS in drought or low flow. Only if the withdrawal would not damage a stream in drought is it approved.

In terms of frack fluids returning from depth to contaminate ground water, the Duke study joins many other data points confirming that has not happened.

In terms of spills and leaks, all companies within the industry must achieve excellence. The rate of spills and leaks must be reduced. Companies must pay to prevent them and pay to clean them up. More companies are adopting practices designed to prevent spills and leaks like placing liners at gas well sites. These practices should become regulatory minimums if not now required.

Again the Susquehanna has never had more legal protection in the form of the TMDL, the August 2010 TDS water rule, the sewer plant clean ups, the drilling standards rule.

Finally, it is also important to understand comparative risks. Less gas means more coal and oil. The environmental impacts from more coal and oil in the mining or drilling process plus the combustion process exceed gas by an enormous amount. We need to drive down the impacts of drilling through regulation and companies developing true culture of safety. But we also need to remember what happens if gas stops. Decisions about one energy source impact other energy sources. It is a reality.

About Me

I am an expert on energy, environment, green economy, competitive electric markets, and utility regulation with unique experience in and out of government. I am a Democratic candidate for Governor of PA. See www.hangerforgovernor.com. You can email me at john@hangerforgovernor.com. I have been both the Secretary of the Pennsylvania Department of Environmental Protection and Commissioner of the Pennsylvania Public Utility Commission. I have made leading regulatory decisions, testified to Congress and state legislatures, and been interviewed countless times, appearing on CBS evening News, NBC Evening New, CNN, BBC, CBC, and many more outlets. I am a 1984 graduate of the University of Pennsylvania and 1979 graduate of Duke University.